Joseph (Jud) B. Judkins

Mr. Judkins concentrates on federal tax controversy matters at every phase of a dispute, including audit, IRS Appeals, and litigation. The application of administrative law principles to Treasury regulations and IRS guidance is a core component of his practice. Mr. Judkins advises clients on a broad spectrum of international and domestic tax disputes, including challenges to the validity of regulations, participation in the agency rulemaking process through the submission of comments and testimony at public hearings, issues involving transfer pricing, employment tax, the section 199 domestic production activities deduction, and the research credit.

• Represented a corporate client before the Tax Court and the court of appeals in a challenge to the validity of transfer pricing regulations. Altera Corp. & Subsidiaries v. Commissioner, 145 T.C. No. 3 (2015), U.S. Court of Appeals for the Ninth Circuit Docket Nos. 16-70496 and 16-70497
• Represented a plaintiff in a suit for refund of penalties for failure to file information returns of foreign corporations. Guardian Industries Corp. v. United States, U.S. District Court for the District of Michigan, No. 4:16-cv-1911
• Represented the plaintiffs in a suit challenging the validity of rules under the Offshore Voluntary Disclosure Program. Maze v. Internal Revenue Service, U.S. District Court for the District of Columbia, No. 1:15-cv-01806, U.S. Court of Appeals for the D.C. Circuit, No. 16-70496
• Represented the plaintiff in a declaratory judgment suit regarding the standard for proving a willful FBAR penalty. Gubser v. Internal Revenue Service, U.S. District Court for the Southern District of Texas, No. 5:15-cv-00298, U.S. Court of Appeals for Fifth Circuit, No. 16-40948